Commodity Markets Oversight Coalition Letter to Chairman Peterson on HR 3795

Commercial aviation helps drive more than 10M American jobs and 5 cents of every dollar of U.S. GDP
Commercial aviation drives more than $1 trillion per year in economic activity
In 2012, U.S. airlines moved more than 48,000 tons of cargo per day
In 2012, the value of a kilogram of U.S. merchandise exported by air averaged 121 times the value exported by sea
For every 100 airline jobs, some 360 are supported outside of the airline industry
Federal taxes constitute $61 – or 20% – of the price of a typical $300 domestic round-trip ticket
In 2011, U.S. airlines carried 16 percent more passengers and cargo using 10 percent less fuel than in 2000
Domestically, airlines drive 5% of economic activity but account for 2% of man-made GHG emissions
From 2000-2011, airlines reduced GHG emissions by 11% while transporting 16% more passengers and cargo
From 1975-2011, U.S. airlines and their partners reduced significant noise exposure by 99%
Commercial air travel is the safest form of intercity transportation in the United States
In the most recent decade, scheduled air service on U.S. airlines was seven times safer than in the 1970s
From 2000-2012, U.S. airlines improved the on-time arrival rate from 72.6% to 81.9%
From 2000-2012, U.S. airlines reduced the flight cancellation rate sharply from 3.30% to 1.29%
Airfares are a bargain: From 2000-2012, U.S. CPI rose 33% while average domestic fare rose just 13%
Adjusted for inflation, the average round-trip domestic airfare fell 15% from 2000
2007 domestic flight delays cost the United States approximately $31 billion
In 2012, the value of U.S. merchandise exported by air reached an all-time high of $427B
In 2012, U.S. exports of air-travel services reached an all-time high of $39.5B, driving a $5.1B trade surplus
In 2012, U.S. passenger and cargo airlines spent more than $50B on fuel, averaging 36% of operating expenses
In 2012, U.S. airlines posted the lowest annual rate of mishandled baggage ever recorded
FAA projects U.S. air travel demand to top 1 billion passengers in 2027
In 2012, US airlines flew 83.4 million passengers in scheduled international service - a record high
In 2012, the total value of merchandise exported from or imported to the United States by air exceeded $927 billion
In 2012, 7.15 teragrams of merchandise was exported from or imported to the United States by air

	Commodity Markets Oversight Coalition Letter to Chairman Peterson on HR 3795
	PubZone1 October 20, 2009 The Honorable Collin Peterson Chairman, Committee on Agriculture U.S. House of Representatives 1301 Longworth House Office Building Washington, DC 20515 Dear Mr. Chairman: We write to again recognize you for your strong leadership in seeking to improve the transparency and strengthen regulatory oversight of our nation’s commodity markets. We are convinced that inadequate regulation of these markets was the single most significant factor in the development of last year’s energy and food commodity price bubbles, and that it contributed greatly to the severity of the larger economic downturn. You have been a leading voice in Congress on the need to address this issue through legislation and we are committed to working with you to see that a strong market reform bill is enacted into law. We are supportive of H.R. 3795, the Over-the-Counter Derivatives Markets Act of 2009, which you introduced last week and thank you for the opportunity to share our views with you on that legislation. We have three suggestions for changes that we believe will strengthen the legislation. First, we would like the Commodity Exchange Act to require the Commodity Futures Trading Commission (CFTC) to impose speculative position limits on all non-commercial traders of commodities across all markets, including the over-the-counter markets. Your bill would give CFTC the authority to take such action for “significant price discovery” contracts, which is a significant improvement over current law. However, we believe all contracts and all trades have an impact on price discovery and should be subject to position limits. This is probably the single most effective change in statute that could be made to ensure excess speculative money does not again flood into commodity markets – as it did last summer – and drive future economically devastating energy and food commodity price bubbles. Secondly, we are concerned about the lack of specificity in the definition of a “Tier-1 financial holding company” in your legislation. While we understand that the Systemic Risk Regulator will make certain determinations as to who qualifies for such a designation, we feel the statute should be clear that all of the major holding companies in the U.S. be included in that definition. Thus, we suggest that you designate any financial holding company with assets above a certain threshold to be considered a Tier-1 financial holding company for purposes of the statute. Finally, we encourage you to enhance the definition of “manipulation” in your legislation to ensure the CFTC is allowed to use the same prosecutorial standard as other federal regulatory agencies, such as the Securities and Exchange Commission, the Federal Energy Regulatory Commission, and the Federal Trade Commission. Current law requires the CFTC to meet a more rigorous standard – a “specific intent” standard – to prove market manipulation than do other financial market regulatory agencies, which only have to prove an action was “reckless” to secure a prosecution. This inconsistency of standards makes it much more difficult for the CFTC to successfully prosecute manipulation and inadequately deters illegal behavior. Again, we thank and commend you for your leadership on these vital issues and will continue to work with you to ensure that strong market reform legislation is enacted into law. Please feel free to contact us if you have questions or if we can be of assistance in your efforts. Sincerely, American Cotton Shippers Association Atlantic Cotton Association Southern Cotton Association Texas Cotton Association Western Cotton Shippers Association Agricultural Retailers Association Air Transport Association American Feed Industry Association Colorado/Wyoming Petroleum Marketers Association Gasoline & Automotive Service Dealers of America, Inc. Florida Petroleum Marketers Association Friends of the Earth Fuel Merchants Association of New Jersey Independent Connecticut Petroleum Association Institute for Agriculture and Trade Policy Louisiana Oil Marketers & Convenience Store Association Maryknoll Office for Global Concerns Massachusetts Oilheat Council National Association of Truckstop Operators Nebraska Petroleum Marketers & Convenience Store Association New England Fuel Institute New York Oil Heating Association Petroleum Marketers & Convenience Store Association Kansas Petroleum Marketers & Convenience Stores of Iowa Petroleum Marketers Association of America Propane Gas Association of New England Public Citizen R-CALF USA South Dakota Petroleum & Propane Marketers Association United Egg Producers Vermont Fuel Dealers Association Western Peanut Growers Cc: The Honorable Frank Lucas, Ranking Member, House Committee on Agriculture PubZone2	A4A advocates measures to support aviation safety, security and well-being.